Perspective information: The Department of Education requires Institutions to reconcile the Direct Loan
Program monthly.
Identification of repeat findings: Yes, see FA-2022-001.
Recommendation: We recommend that the DL Reconciliation process include cooperation between the
business and financial aid offices given the financial aid office is the source of information reported to and
from COD, and the business office is responsible for the drawdown of funds from the Department of
Education’s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency
of the DL Reconciliation must be monthly to meet compliance requirements. The financial and business
offices should first perform an internal reconciliation of their records, identifying any reconciling items at a
detailed (student) level. Once this internal reconciliation is complete, the University should perform the
external reconciliation to COD’s records via the SAS data file, identifying any reconciling items at a detailed
level. Reconciling items from both the internal and external reconciliations should be evaluated for items
that require corrective action(s). Corrective actions should be taken timely to correct any issues identified
by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted
disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with
Department of Education’s Cash Management requirements as of month-end. The University should retain
these reconciliations, including all supporting documentation, for purposes of internal and/or external
examination.
Views of responsible officials: See Client’s Corrective Action Plan.
Perspective information: The Department of Education requires Institutions to reconcile the Direct Loan
Program monthly.
Identification of repeat findings: Yes, see FA-2022-001.
Recommendation: We recommend that the DL Reconciliation process include cooperation between the
business and financial aid offices given the financial aid office is the source of information reported to and
from COD, and the business office is responsible for the drawdown of funds from the Department of
Education’s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency
of the DL Reconciliation must be monthly to meet compliance requirements. The financial and business
offices should first perform an internal reconciliation of their records, identifying any reconciling items at a
detailed (student) level. Once this internal reconciliation is complete, the University should perform the
external reconciliation to COD’s records via the SAS data file, identifying any reconciling items at a detailed
level. Reconciling items from both the internal and external reconciliations should be evaluated for items
that require corrective action(s). Corrective actions should be taken timely to correct any issues identified
by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted
disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with
Department of Education’s Cash Management requirements as of month-end. The University should retain
these reconciliations, including all supporting documentation, for purposes of internal and/or external
examination.
Views of responsible officials: See Client’s Corrective Action Plan.
Perspective information: The Department of Education requires Institutions to reconcile the Direct Loan
Program monthly.
Identification of repeat findings: Yes, see FA-2022-001.
Recommendation: We recommend that the DL Reconciliation process include cooperation between the
business and financial aid offices given the financial aid office is the source of information reported to and
from COD, and the business office is responsible for the drawdown of funds from the Department of
Education’s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency
of the DL Reconciliation must be monthly to meet compliance requirements. The financial and business
offices should first perform an internal reconciliation of their records, identifying any reconciling items at a
detailed (student) level. Once this internal reconciliation is complete, the University should perform the
external reconciliation to COD’s records via the SAS data file, identifying any reconciling items at a detailed
level. Reconciling items from both the internal and external reconciliations should be evaluated for items
that require corrective action(s). Corrective actions should be taken timely to correct any issues identified
by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted
disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with
Department of Education’s Cash Management requirements as of month-end. The University should retain
these reconciliations, including all supporting documentation, for purposes of internal and/or external
examination.
Views of responsible officials: See Client’s Corrective Action Plan.
Perspective information: The Department of Education requires Institutions to reconcile the Direct Loan
Program monthly.
Identification of repeat findings: Yes, see FA-2022-001.
Recommendation: We recommend that the DL Reconciliation process include cooperation between the
business and financial aid offices given the financial aid office is the source of information reported to and
from COD, and the business office is responsible for the drawdown of funds from the Department of
Education’s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency
of the DL Reconciliation must be monthly to meet compliance requirements. The financial and business
offices should first perform an internal reconciliation of their records, identifying any reconciling items at a
detailed (student) level. Once this internal reconciliation is complete, the University should perform the
external reconciliation to COD’s records via the SAS data file, identifying any reconciling items at a detailed
level. Reconciling items from both the internal and external reconciliations should be evaluated for items
that require corrective action(s). Corrective actions should be taken timely to correct any issues identified
by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted
disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with
Department of Education’s Cash Management requirements as of month-end. The University should retain
these reconciliations, including all supporting documentation, for purposes of internal and/or external
examination.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment
reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student
Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective
management of the programs. Enrollment information must be reported within 60 days whenever enrollment
status changes for students unless a roster is submitted within 60 days. These changes include reductions or
increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence.
Condition: We tested NSLDS Enrollment Detail Records for nine students with changes in enrollment. Out
of those nine, we noted that none of NSLDS status was changed within a timely manner.
Cause: The enrollment data transmitted to NSC was not accurate.
Effect: Enrollment statuses in NSLDS for the affected individuals were not correct and likely resulted in
improper loan deferments and interest subsidies on outstanding loans.
Questioned costs: $-0- Perspective information: See table below:
Identification of repeat findings: Yes, see FA-2022-002.
Recommendation: The University should work with its Information Technology Department and NSC to
determine the root cause of the enrollment reporting errors and develop corrective action as soon as possible
to avoid future reporting inaccuracies. The corrective action should be closely monitored by the Registrar
on test basis to ensure the process is functioning as intended and resulting in accurate enrollment reporting.
Views of responsible officials: See Client’s Corrective Action Plan
Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment
reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student
Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective
management of the programs. Enrollment information must be reported within 60 days whenever enrollment
status changes for students unless a roster is submitted within 60 days. These changes include reductions or
increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence.
Condition: We tested NSLDS Enrollment Detail Records for nine students with changes in enrollment. Out
of those nine, we noted that none of NSLDS status was changed within a timely manner.
Cause: The enrollment data transmitted to NSC was not accurate.
Effect: Enrollment statuses in NSLDS for the affected individuals were not correct and likely resulted in
improper loan deferments and interest subsidies on outstanding loans.
Questioned costs: $-0- Perspective information: See table below:
Identification of repeat findings: Yes, see FA-2022-002.
Recommendation: The University should work with its Information Technology Department and NSC to
determine the root cause of the enrollment reporting errors and develop corrective action as soon as possible
to avoid future reporting inaccuracies. The corrective action should be closely monitored by the Registrar
on test basis to ensure the process is functioning as intended and resulting in accurate enrollment reporting.
Views of responsible officials: See Client’s Corrective Action Plan
Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment
reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student
Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective
management of the programs. Enrollment information must be reported within 60 days whenever enrollment
status changes for students unless a roster is submitted within 60 days. These changes include reductions or
increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence.
Condition: We tested NSLDS Enrollment Detail Records for nine students with changes in enrollment. Out
of those nine, we noted that none of NSLDS status was changed within a timely manner.
Cause: The enrollment data transmitted to NSC was not accurate.
Effect: Enrollment statuses in NSLDS for the affected individuals were not correct and likely resulted in
improper loan deferments and interest subsidies on outstanding loans.
Questioned costs: $-0- Perspective information: See table below:
Identification of repeat findings: Yes, see FA-2022-002.
Recommendation: The University should work with its Information Technology Department and NSC to
determine the root cause of the enrollment reporting errors and develop corrective action as soon as possible
to avoid future reporting inaccuracies. The corrective action should be closely monitored by the Registrar
on test basis to ensure the process is functioning as intended and resulting in accurate enrollment reporting.
Views of responsible officials: See Client’s Corrective Action Plan
Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment
reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student
Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective
management of the programs. Enrollment information must be reported within 60 days whenever enrollment
status changes for students unless a roster is submitted within 60 days. These changes include reductions or
increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence.
Condition: We tested NSLDS Enrollment Detail Records for nine students with changes in enrollment. Out
of those nine, we noted that none of NSLDS status was changed within a timely manner.
Cause: The enrollment data transmitted to NSC was not accurate.
Effect: Enrollment statuses in NSLDS for the affected individuals were not correct and likely resulted in
improper loan deferments and interest subsidies on outstanding loans.
Questioned costs: $-0- Perspective information: See table below:
Identification of repeat findings: Yes, see FA-2022-002.
Recommendation: The University should work with its Information Technology Department and NSC to
determine the root cause of the enrollment reporting errors and develop corrective action as soon as possible
to avoid future reporting inaccuracies. The corrective action should be closely monitored by the Registrar
on test basis to ensure the process is functioning as intended and resulting in accurate enrollment reporting.
Views of responsible officials: See Client’s Corrective Action Plan
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized
Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower
ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the
student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b),
(1) & 34 CFR 674.42(b)].
Condition: For 11 of student files examined where students with direct loans withdrew during FY23, we did
not find satisfactory documentation to show that the University complied with exit counseling requirements
for four of them and for six of them, counseling wasn’t done timely (total exceptions 10 out of 11 files where
such counseling was required. Cause: Weak processes and controls over ensuring exit counseling is performed as well as a lack of
recordkeeping to evidence exit counseling requirements were met by the University.
Effect: For students with a break in enrollment, the University did not meet its responsibilities to provide
these individuals with required exit counseling information.
Questioned costs: $-0-.
Perspective information: See table below: Identification of repeat findings: Yes, see FA-2022-003.
Recommendation: The Financial Aid Director should review the Department of Education’s requirements
of Institutions related to exit counseling and implement controls to ensure those requirements are met. We
recommend that the Department of Education’s Direct Loan Exit Counseling Guide be mailed to the
permanent address on record for students who have separated service along with a letter informing them to
read the material and perform exit counseling online as a requirement of their federal loans. The materials
sent to the students should be dated and copies retained in the students’ files as evidence of the University’s
compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized
Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower
ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the
student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b),
(1) & 34 CFR 674.42(b)].
Condition: For 11 of student files examined where students with direct loans withdrew during FY23, we did
not find satisfactory documentation to show that the University complied with exit counseling requirements
for four of them and for six of them, counseling wasn’t done timely (total exceptions 10 out of 11 files where
such counseling was required. Cause: Weak processes and controls over ensuring exit counseling is performed as well as a lack of
recordkeeping to evidence exit counseling requirements were met by the University.
Effect: For students with a break in enrollment, the University did not meet its responsibilities to provide
these individuals with required exit counseling information.
Questioned costs: $-0-.
Perspective information: See table below: Identification of repeat findings: Yes, see FA-2022-003.
Recommendation: The Financial Aid Director should review the Department of Education’s requirements
of Institutions related to exit counseling and implement controls to ensure those requirements are met. We
recommend that the Department of Education’s Direct Loan Exit Counseling Guide be mailed to the
permanent address on record for students who have separated service along with a letter informing them to
read the material and perform exit counseling online as a requirement of their federal loans. The materials
sent to the students should be dated and copies retained in the students’ files as evidence of the University’s
compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized
Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower
ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the
student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b),
(1) & 34 CFR 674.42(b)].
Condition: For 11 of student files examined where students with direct loans withdrew during FY23, we did
not find satisfactory documentation to show that the University complied with exit counseling requirements
for four of them and for six of them, counseling wasn’t done timely (total exceptions 10 out of 11 files where
such counseling was required. Cause: Weak processes and controls over ensuring exit counseling is performed as well as a lack of
recordkeeping to evidence exit counseling requirements were met by the University.
Effect: For students with a break in enrollment, the University did not meet its responsibilities to provide
these individuals with required exit counseling information.
Questioned costs: $-0-.
Perspective information: See table below: Identification of repeat findings: Yes, see FA-2022-003.
Recommendation: The Financial Aid Director should review the Department of Education’s requirements
of Institutions related to exit counseling and implement controls to ensure those requirements are met. We
recommend that the Department of Education’s Direct Loan Exit Counseling Guide be mailed to the
permanent address on record for students who have separated service along with a letter informing them to
read the material and perform exit counseling online as a requirement of their federal loans. The materials
sent to the students should be dated and copies retained in the students’ files as evidence of the University’s
compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized
Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower
ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the
student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b),
(1) & 34 CFR 674.42(b)].
Condition: For 11 of student files examined where students with direct loans withdrew during FY23, we did
not find satisfactory documentation to show that the University complied with exit counseling requirements
for four of them and for six of them, counseling wasn’t done timely (total exceptions 10 out of 11 files where
such counseling was required. Cause: Weak processes and controls over ensuring exit counseling is performed as well as a lack of
recordkeeping to evidence exit counseling requirements were met by the University.
Effect: For students with a break in enrollment, the University did not meet its responsibilities to provide
these individuals with required exit counseling information.
Questioned costs: $-0-.
Perspective information: See table below: Identification of repeat findings: Yes, see FA-2022-003.
Recommendation: The Financial Aid Director should review the Department of Education’s requirements
of Institutions related to exit counseling and implement controls to ensure those requirements are met. We
recommend that the Department of Education’s Direct Loan Exit Counseling Guide be mailed to the
permanent address on record for students who have separated service along with a letter informing them to
read the material and perform exit counseling online as a requirement of their federal loans. The materials
sent to the students should be dated and copies retained in the students’ files as evidence of the University’s
compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student remains eligible to receive financial aid prior to
disbursement of funds. From appendix A of compliance supplement: Student must maintain good standing,
or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11,
20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Satisfactory academic progress (SAP) is defined as
Maintenance of satisfactory progress (2.0 GPA).
Condition: For two of the 49 student files tested receiving financial aid during FY23, the GPA was below
two out of 10 students with unsatisfactory academic progress were allowed to continue to receive federal aid
with no evidence of obtaining a waiver.
Cause: Weak internal control processes over SAP for students as well as the student appeal process.
Effect: For students with a GPA < 2, the University failed to meet its obligation to assist the students with
the appeals process.
Questioned costs: $24,794
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-004.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students with unsatisfactory academic performance students had no documented appeal process for
students to continue to receive aid and develop corrective action as soon as possible to avoid future issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student remains eligible to receive financial aid prior to
disbursement of funds. From appendix A of compliance supplement: Student must maintain good standing,
or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11,
20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Satisfactory academic progress (SAP) is defined as
Maintenance of satisfactory progress (2.0 GPA).
Condition: For two of the 49 student files tested receiving financial aid during FY23, the GPA was below
two out of 10 students with unsatisfactory academic progress were allowed to continue to receive federal aid
with no evidence of obtaining a waiver.
Cause: Weak internal control processes over SAP for students as well as the student appeal process.
Effect: For students with a GPA < 2, the University failed to meet its obligation to assist the students with
the appeals process.
Questioned costs: $24,794
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-004.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students with unsatisfactory academic performance students had no documented appeal process for
students to continue to receive aid and develop corrective action as soon as possible to avoid future issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student remains eligible to receive financial aid prior to
disbursement of funds. From appendix A of compliance supplement: Student must maintain good standing,
or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11,
20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Satisfactory academic progress (SAP) is defined as
Maintenance of satisfactory progress (2.0 GPA).
Condition: For two of the 49 student files tested receiving financial aid during FY23, the GPA was below
two out of 10 students with unsatisfactory academic progress were allowed to continue to receive federal aid
with no evidence of obtaining a waiver.
Cause: Weak internal control processes over SAP for students as well as the student appeal process.
Effect: For students with a GPA < 2, the University failed to meet its obligation to assist the students with
the appeals process.
Questioned costs: $24,794
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-004.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students with unsatisfactory academic performance students had no documented appeal process for
students to continue to receive aid and develop corrective action as soon as possible to avoid future issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student remains eligible to receive financial aid prior to
disbursement of funds. From appendix A of compliance supplement: Student must maintain good standing,
or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11,
20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Satisfactory academic progress (SAP) is defined as
Maintenance of satisfactory progress (2.0 GPA).
Condition: For two of the 49 student files tested receiving financial aid during FY23, the GPA was below
two out of 10 students with unsatisfactory academic progress were allowed to continue to receive federal aid
with no evidence of obtaining a waiver.
Cause: Weak internal control processes over SAP for students as well as the student appeal process.
Effect: For students with a GPA < 2, the University failed to meet its obligation to assist the students with
the appeals process.
Questioned costs: $24,794
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-004.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students with unsatisfactory academic performance students had no documented appeal process for
students to continue to receive aid and develop corrective action as soon as possible to avoid future issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution refunds calculated for students who withdrew during a semester
be remitted to the Department of Education timely, within 45 days of withdrawal.
Condition: Fourteen students were selected for withdrawal test work. Of those fourteen students, the
Institution calculated an amount that needed to be returned for 8 of those students (four students tested didn’t
have to return any funds, met the requirement to keep all aid received). Six of those eight students who
required funds to be returned based upon their withdrawal terms and resulting return of funding calculations
were not returned timely to the Department of Education.
Cause: Weak process and controls over the return of funds for students who withdrew from the Institution.
Effect: Funds were held in the University’s cash account longer than necessary and such funds were no longer
technically the property of the University after the student withdrew from the University.
Questioned costs: $-0-
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-005.
Recommendation: The University should increase its efforts through training to ensure that federal refunds
are calculated and remitted timely when students withdraw from the Institution.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution refunds calculated for students who withdrew during a semester
be remitted to the Department of Education timely, within 45 days of withdrawal.
Condition: Fourteen students were selected for withdrawal test work. Of those fourteen students, the
Institution calculated an amount that needed to be returned for 8 of those students (four students tested didn’t
have to return any funds, met the requirement to keep all aid received). Six of those eight students who
required funds to be returned based upon their withdrawal terms and resulting return of funding calculations
were not returned timely to the Department of Education.
Cause: Weak process and controls over the return of funds for students who withdrew from the Institution.
Effect: Funds were held in the University’s cash account longer than necessary and such funds were no longer
technically the property of the University after the student withdrew from the University.
Questioned costs: $-0-
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-005.
Recommendation: The University should increase its efforts through training to ensure that federal refunds
are calculated and remitted timely when students withdraw from the Institution.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution refunds calculated for students who withdrew during a semester
be remitted to the Department of Education timely, within 45 days of withdrawal.
Condition: Fourteen students were selected for withdrawal test work. Of those fourteen students, the
Institution calculated an amount that needed to be returned for 8 of those students (four students tested didn’t
have to return any funds, met the requirement to keep all aid received). Six of those eight students who
required funds to be returned based upon their withdrawal terms and resulting return of funding calculations
were not returned timely to the Department of Education.
Cause: Weak process and controls over the return of funds for students who withdrew from the Institution.
Effect: Funds were held in the University’s cash account longer than necessary and such funds were no longer
technically the property of the University after the student withdrew from the University.
Questioned costs: $-0-
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-005.
Recommendation: The University should increase its efforts through training to ensure that federal refunds
are calculated and remitted timely when students withdraw from the Institution.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution refunds calculated for students who withdrew during a semester
be remitted to the Department of Education timely, within 45 days of withdrawal.
Condition: Fourteen students were selected for withdrawal test work. Of those fourteen students, the
Institution calculated an amount that needed to be returned for 8 of those students (four students tested didn’t
have to return any funds, met the requirement to keep all aid received). Six of those eight students who
required funds to be returned based upon their withdrawal terms and resulting return of funding calculations
were not returned timely to the Department of Education.
Cause: Weak process and controls over the return of funds for students who withdrew from the Institution.
Effect: Funds were held in the University’s cash account longer than necessary and such funds were no longer
technically the property of the University after the student withdrew from the University.
Questioned costs: $-0-
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-005.
Recommendation: The University should increase its efforts through training to ensure that federal refunds
are calculated and remitted timely when students withdraw from the Institution.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student with Verification code V4 or V5 has a high school
completion status and has signed an Identity of education purpose statement.
Condition: For one of the five student files tested that required verification of high school completion and a
signed Identity of education statement of the total 49 students tested who received financial aid during FY23,
the verification process was not documented.
Cause: Weak internal control processes over required verification for students.
Effect: For students with verification codes V4 or V5, the University failed to maintain the student’s signed
Identity of educational purpose statement.
Questioned costs: $7,947
Perspective information: See table below: Identification of repeat findings: Not a repeat finding.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students were not verified properly and develop corrective action as soon as possible to avoid any
further issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student with Verification code V4 or V5 has a high school
completion status and has signed an Identity of education purpose statement.
Condition: For one of the five student files tested that required verification of high school completion and a
signed Identity of education statement of the total 49 students tested who received financial aid during FY23,
the verification process was not documented.
Cause: Weak internal control processes over required verification for students.
Effect: For students with verification codes V4 or V5, the University failed to maintain the student’s signed
Identity of educational purpose statement.
Questioned costs: $7,947
Perspective information: See table below: Identification of repeat findings: Not a repeat finding.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students were not verified properly and develop corrective action as soon as possible to avoid any
further issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student with Verification code V4 or V5 has a high school
completion status and has signed an Identity of education purpose statement.
Condition: For one of the five student files tested that required verification of high school completion and a
signed Identity of education statement of the total 49 students tested who received financial aid during FY23,
the verification process was not documented.
Cause: Weak internal control processes over required verification for students.
Effect: For students with verification codes V4 or V5, the University failed to maintain the student’s signed
Identity of educational purpose statement.
Questioned costs: $7,947
Perspective information: See table below: Identification of repeat findings: Not a repeat finding.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students were not verified properly and develop corrective action as soon as possible to avoid any
further issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student with Verification code V4 or V5 has a high school
completion status and has signed an Identity of education purpose statement.
Condition: For one of the five student files tested that required verification of high school completion and a
signed Identity of education statement of the total 49 students tested who received financial aid during FY23,
the verification process was not documented.
Cause: Weak internal control processes over required verification for students.
Effect: For students with verification codes V4 or V5, the University failed to maintain the student’s signed
Identity of educational purpose statement.
Questioned costs: $7,947
Perspective information: See table below: Identification of repeat findings: Not a repeat finding.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students were not verified properly and develop corrective action as soon as possible to avoid any
further issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve
publicly posting completed forms on the Institution’s website. The forms must be conspicuously posted on
the Institution’s primary website on the same page as the reports of the IHE’s activities as to the emergency
financial aid grants to students (Student Aid Portion) are posted. This information must also be updated no
later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition: We tested two quarterly reports prepared by Virginia Union University to verify timely posting
to website and accuracy in reporting. Of the two tested we were not able to verify that one had been posted
timely to VUU’s website and for one of the two tested, the form was not accurate; the amount distributed did
not agree with underlying documentation.
Cause: Weak process and controls over the preparation and review for the compliance over the public
reporting requirements and accurate filing.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: This finding is related to timely posting was identified from testing two of the four
required quarterly reports and timely filing could not be verified for one of the two reports tested and one
report was not accurate.
Identification of repeat findings: Yes, See FA-2022-006.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve
publicly posting completed forms on the Institution’s website. The forms must be conspicuously posted on
the Institution’s primary website on the same page as the reports of the IHE’s activities as to the emergency
financial aid grants to students (Student Aid Portion) are posted. This information must also be updated no
later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition: We tested two quarterly reports prepared by Virginia Union University to verify timely posting
to website and accuracy in reporting. Of the two tested we were not able to verify that one had been posted
timely to VUU’s website and for one of the two tested, the form was not accurate; the amount distributed did
not agree with underlying documentation.
Cause: Weak process and controls over the preparation and review for the compliance over the public
reporting requirements and accurate filing.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: This finding is related to timely posting was identified from testing two of the four
required quarterly reports and timely filing could not be verified for one of the two reports tested and one
report was not accurate.
Identification of repeat findings: Yes, See FA-2022-006.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve
publicly posting completed forms on the Institution’s website. The forms must be conspicuously posted on
the Institution’s primary website on the same page as the reports of the IHE’s activities as to the emergency
financial aid grants to students (Student Aid Portion) are posted. This information must also be updated no
later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition: We tested two quarterly reports prepared by Virginia Union University to verify timely posting
to website and accuracy in reporting. Of the two tested we were not able to verify that one had been posted
timely to VUU’s website and for one of the two tested, the form was not accurate; the amount distributed did
not agree with underlying documentation.
Cause: Weak process and controls over the preparation and review for the compliance over the public
reporting requirements and accurate filing.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: This finding is related to timely posting was identified from testing two of the four
required quarterly reports and timely filing could not be verified for one of the two reports tested and one
report was not accurate.
Identification of repeat findings: Yes, See FA-2022-006.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Recipients of HEERF funding must acknowledge that it may not condition the receipt of an
emergency financial aid grant on continued or future enrollment with the Recipient. Recipients also
acknowledge that it may not require a student to consent to the application of the emergency financial aid
grant to the student’s outstanding account balance as a condition of receipt of or eligibility for an emergency
financial aid grant funding. The recipient also acknowledges that adding preconditions to receiving a
financial aid grant that thwart this requirement may be subjected to oversight and corrective action. In
consideration for this award, Recipients agree that they hold these grant funds in trust for students and act in
the nature of a fiduciary for students.
Condition: We tested 36 students receiving student aid to verify that students had been notified of their
award, received the funds directly and funds were applied as student requested on their signed and dated
HEERF Notification and Authorization Form. Of the 36 tested 10 had issues. For 3 students, their account
was credited for the award, and they had authorized payment by check; For 7 students, there was no form
found directing how funds should be disbursed to them from VUU.
Cause: Weak processes and controls over the notification of students of their award and distribution of awards
based on student’s authorization/instruction.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: These findings relate to the inappropriate distribution of awards to student
accounts when students had instructed that their award not be posted to their student’s account and authorized
they be made by check. For the other students the funds were posted to the student accounts and there was no
evidence of authorization from the student.
Identification of repeat findings: Not a repeat finding.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Recipients of HEERF funding must acknowledge that it may not condition the receipt of an
emergency financial aid grant on continued or future enrollment with the Recipient. Recipients also
acknowledge that it may not require a student to consent to the application of the emergency financial aid
grant to the student’s outstanding account balance as a condition of receipt of or eligibility for an emergency
financial aid grant funding. The recipient also acknowledges that adding preconditions to receiving a
financial aid grant that thwart this requirement may be subjected to oversight and corrective action. In
consideration for this award, Recipients agree that they hold these grant funds in trust for students and act in
the nature of a fiduciary for students.
Condition: We tested 36 students receiving student aid to verify that students had been notified of their
award, received the funds directly and funds were applied as student requested on their signed and dated
HEERF Notification and Authorization Form. Of the 36 tested 10 had issues. For 3 students, their account
was credited for the award, and they had authorized payment by check; For 7 students, there was no form
found directing how funds should be disbursed to them from VUU.
Cause: Weak processes and controls over the notification of students of their award and distribution of awards
based on student’s authorization/instruction.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: These findings relate to the inappropriate distribution of awards to student
accounts when students had instructed that their award not be posted to their student’s account and authorized
they be made by check. For the other students the funds were posted to the student accounts and there was no
evidence of authorization from the student.
Identification of repeat findings: Not a repeat finding.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Recipients of HEERF funding must acknowledge that it may not condition the receipt of an
emergency financial aid grant on continued or future enrollment with the Recipient. Recipients also
acknowledge that it may not require a student to consent to the application of the emergency financial aid
grant to the student’s outstanding account balance as a condition of receipt of or eligibility for an emergency
financial aid grant funding. The recipient also acknowledges that adding preconditions to receiving a
financial aid grant that thwart this requirement may be subjected to oversight and corrective action. In
consideration for this award, Recipients agree that they hold these grant funds in trust for students and act in
the nature of a fiduciary for students.
Condition: We tested 36 students receiving student aid to verify that students had been notified of their
award, received the funds directly and funds were applied as student requested on their signed and dated
HEERF Notification and Authorization Form. Of the 36 tested 10 had issues. For 3 students, their account
was credited for the award, and they had authorized payment by check; For 7 students, there was no form
found directing how funds should be disbursed to them from VUU.
Cause: Weak processes and controls over the notification of students of their award and distribution of awards
based on student’s authorization/instruction.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: These findings relate to the inappropriate distribution of awards to student
accounts when students had instructed that their award not be posted to their student’s account and authorized
they be made by check. For the other students the funds were posted to the student accounts and there was no
evidence of authorization from the student.
Identification of repeat findings: Not a repeat finding.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Perspective information: The Department of Education requires Institutions to reconcile the Direct Loan
Program monthly.
Identification of repeat findings: Yes, see FA-2022-001.
Recommendation: We recommend that the DL Reconciliation process include cooperation between the
business and financial aid offices given the financial aid office is the source of information reported to and
from COD, and the business office is responsible for the drawdown of funds from the Department of
Education’s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency
of the DL Reconciliation must be monthly to meet compliance requirements. The financial and business
offices should first perform an internal reconciliation of their records, identifying any reconciling items at a
detailed (student) level. Once this internal reconciliation is complete, the University should perform the
external reconciliation to COD’s records via the SAS data file, identifying any reconciling items at a detailed
level. Reconciling items from both the internal and external reconciliations should be evaluated for items
that require corrective action(s). Corrective actions should be taken timely to correct any issues identified
by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted
disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with
Department of Education’s Cash Management requirements as of month-end. The University should retain
these reconciliations, including all supporting documentation, for purposes of internal and/or external
examination.
Views of responsible officials: See Client’s Corrective Action Plan.
Perspective information: The Department of Education requires Institutions to reconcile the Direct Loan
Program monthly.
Identification of repeat findings: Yes, see FA-2022-001.
Recommendation: We recommend that the DL Reconciliation process include cooperation between the
business and financial aid offices given the financial aid office is the source of information reported to and
from COD, and the business office is responsible for the drawdown of funds from the Department of
Education’s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency
of the DL Reconciliation must be monthly to meet compliance requirements. The financial and business
offices should first perform an internal reconciliation of their records, identifying any reconciling items at a
detailed (student) level. Once this internal reconciliation is complete, the University should perform the
external reconciliation to COD’s records via the SAS data file, identifying any reconciling items at a detailed
level. Reconciling items from both the internal and external reconciliations should be evaluated for items
that require corrective action(s). Corrective actions should be taken timely to correct any issues identified
by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted
disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with
Department of Education’s Cash Management requirements as of month-end. The University should retain
these reconciliations, including all supporting documentation, for purposes of internal and/or external
examination.
Views of responsible officials: See Client’s Corrective Action Plan.
Perspective information: The Department of Education requires Institutions to reconcile the Direct Loan
Program monthly.
Identification of repeat findings: Yes, see FA-2022-001.
Recommendation: We recommend that the DL Reconciliation process include cooperation between the
business and financial aid offices given the financial aid office is the source of information reported to and
from COD, and the business office is responsible for the drawdown of funds from the Department of
Education’s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency
of the DL Reconciliation must be monthly to meet compliance requirements. The financial and business
offices should first perform an internal reconciliation of their records, identifying any reconciling items at a
detailed (student) level. Once this internal reconciliation is complete, the University should perform the
external reconciliation to COD’s records via the SAS data file, identifying any reconciling items at a detailed
level. Reconciling items from both the internal and external reconciliations should be evaluated for items
that require corrective action(s). Corrective actions should be taken timely to correct any issues identified
by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted
disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with
Department of Education’s Cash Management requirements as of month-end. The University should retain
these reconciliations, including all supporting documentation, for purposes of internal and/or external
examination.
Views of responsible officials: See Client’s Corrective Action Plan.
Perspective information: The Department of Education requires Institutions to reconcile the Direct Loan
Program monthly.
Identification of repeat findings: Yes, see FA-2022-001.
Recommendation: We recommend that the DL Reconciliation process include cooperation between the
business and financial aid offices given the financial aid office is the source of information reported to and
from COD, and the business office is responsible for the drawdown of funds from the Department of
Education’s G5 website as well as for disbursing DL funds to student accounts. At a minimum, the frequency
of the DL Reconciliation must be monthly to meet compliance requirements. The financial and business
offices should first perform an internal reconciliation of their records, identifying any reconciling items at a
detailed (student) level. Once this internal reconciliation is complete, the University should perform the
external reconciliation to COD’s records via the SAS data file, identifying any reconciling items at a detailed
level. Reconciling items from both the internal and external reconciliations should be evaluated for items
that require corrective action(s). Corrective actions should be taken timely to correct any issues identified
by this process. Finally, cumulative data in G5, such as net drawdowns and net accepted and posted
disbursements, should be incorporated into the reconciliation to ensure the University is in compliance with
Department of Education’s Cash Management requirements as of month-end. The University should retain
these reconciliations, including all supporting documentation, for purposes of internal and/or external
examination.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment
reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student
Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective
management of the programs. Enrollment information must be reported within 60 days whenever enrollment
status changes for students unless a roster is submitted within 60 days. These changes include reductions or
increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence.
Condition: We tested NSLDS Enrollment Detail Records for nine students with changes in enrollment. Out
of those nine, we noted that none of NSLDS status was changed within a timely manner.
Cause: The enrollment data transmitted to NSC was not accurate.
Effect: Enrollment statuses in NSLDS for the affected individuals were not correct and likely resulted in
improper loan deferments and interest subsidies on outstanding loans.
Questioned costs: $-0- Perspective information: See table below:
Identification of repeat findings: Yes, see FA-2022-002.
Recommendation: The University should work with its Information Technology Department and NSC to
determine the root cause of the enrollment reporting errors and develop corrective action as soon as possible
to avoid future reporting inaccuracies. The corrective action should be closely monitored by the Registrar
on test basis to ensure the process is functioning as intended and resulting in accurate enrollment reporting.
Views of responsible officials: See Client’s Corrective Action Plan
Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment
reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student
Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective
management of the programs. Enrollment information must be reported within 60 days whenever enrollment
status changes for students unless a roster is submitted within 60 days. These changes include reductions or
increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence.
Condition: We tested NSLDS Enrollment Detail Records for nine students with changes in enrollment. Out
of those nine, we noted that none of NSLDS status was changed within a timely manner.
Cause: The enrollment data transmitted to NSC was not accurate.
Effect: Enrollment statuses in NSLDS for the affected individuals were not correct and likely resulted in
improper loan deferments and interest subsidies on outstanding loans.
Questioned costs: $-0- Perspective information: See table below:
Identification of repeat findings: Yes, see FA-2022-002.
Recommendation: The University should work with its Information Technology Department and NSC to
determine the root cause of the enrollment reporting errors and develop corrective action as soon as possible
to avoid future reporting inaccuracies. The corrective action should be closely monitored by the Registrar
on test basis to ensure the process is functioning as intended and resulting in accurate enrollment reporting.
Views of responsible officials: See Client’s Corrective Action Plan
Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment
reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student
Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective
management of the programs. Enrollment information must be reported within 60 days whenever enrollment
status changes for students unless a roster is submitted within 60 days. These changes include reductions or
increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence.
Condition: We tested NSLDS Enrollment Detail Records for nine students with changes in enrollment. Out
of those nine, we noted that none of NSLDS status was changed within a timely manner.
Cause: The enrollment data transmitted to NSC was not accurate.
Effect: Enrollment statuses in NSLDS for the affected individuals were not correct and likely resulted in
improper loan deferments and interest subsidies on outstanding loans.
Questioned costs: $-0- Perspective information: See table below:
Identification of repeat findings: Yes, see FA-2022-002.
Recommendation: The University should work with its Information Technology Department and NSC to
determine the root cause of the enrollment reporting errors and develop corrective action as soon as possible
to avoid future reporting inaccuracies. The corrective action should be closely monitored by the Registrar
on test basis to ensure the process is functioning as intended and resulting in accurate enrollment reporting.
Views of responsible officials: See Client’s Corrective Action Plan
Criteria: Under the Pell grant and ED loan programs, Institutions are responsible for timely enrollment
reporting to NSLDS whether they report directly or via a third-party servicer such as the National Student
Clearinghouse (NSC). Enrollment reporting in a timely and accurate manner is critical for effective
management of the programs. Enrollment information must be reported within 60 days whenever enrollment
status changes for students unless a roster is submitted within 60 days. These changes include reductions or
increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence.
Condition: We tested NSLDS Enrollment Detail Records for nine students with changes in enrollment. Out
of those nine, we noted that none of NSLDS status was changed within a timely manner.
Cause: The enrollment data transmitted to NSC was not accurate.
Effect: Enrollment statuses in NSLDS for the affected individuals were not correct and likely resulted in
improper loan deferments and interest subsidies on outstanding loans.
Questioned costs: $-0- Perspective information: See table below:
Identification of repeat findings: Yes, see FA-2022-002.
Recommendation: The University should work with its Information Technology Department and NSC to
determine the root cause of the enrollment reporting errors and develop corrective action as soon as possible
to avoid future reporting inaccuracies. The corrective action should be closely monitored by the Registrar
on test basis to ensure the process is functioning as intended and resulting in accurate enrollment reporting.
Views of responsible officials: See Client’s Corrective Action Plan
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized
Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower
ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the
student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b),
(1) & 34 CFR 674.42(b)].
Condition: For 11 of student files examined where students with direct loans withdrew during FY23, we did
not find satisfactory documentation to show that the University complied with exit counseling requirements
for four of them and for six of them, counseling wasn’t done timely (total exceptions 10 out of 11 files where
such counseling was required. Cause: Weak processes and controls over ensuring exit counseling is performed as well as a lack of
recordkeeping to evidence exit counseling requirements were met by the University.
Effect: For students with a break in enrollment, the University did not meet its responsibilities to provide
these individuals with required exit counseling information.
Questioned costs: $-0-.
Perspective information: See table below: Identification of repeat findings: Yes, see FA-2022-003.
Recommendation: The Financial Aid Director should review the Department of Education’s requirements
of Institutions related to exit counseling and implement controls to ensure those requirements are met. We
recommend that the Department of Education’s Direct Loan Exit Counseling Guide be mailed to the
permanent address on record for students who have separated service along with a letter informing them to
read the material and perform exit counseling online as a requirement of their federal loans. The materials
sent to the students should be dated and copies retained in the students’ files as evidence of the University’s
compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized
Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower
ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the
student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b),
(1) & 34 CFR 674.42(b)].
Condition: For 11 of student files examined where students with direct loans withdrew during FY23, we did
not find satisfactory documentation to show that the University complied with exit counseling requirements
for four of them and for six of them, counseling wasn’t done timely (total exceptions 10 out of 11 files where
such counseling was required. Cause: Weak processes and controls over ensuring exit counseling is performed as well as a lack of
recordkeeping to evidence exit counseling requirements were met by the University.
Effect: For students with a break in enrollment, the University did not meet its responsibilities to provide
these individuals with required exit counseling information.
Questioned costs: $-0-.
Perspective information: See table below: Identification of repeat findings: Yes, see FA-2022-003.
Recommendation: The Financial Aid Director should review the Department of Education’s requirements
of Institutions related to exit counseling and implement controls to ensure those requirements are met. We
recommend that the Department of Education’s Direct Loan Exit Counseling Guide be mailed to the
permanent address on record for students who have separated service along with a letter informing them to
read the material and perform exit counseling online as a requirement of their federal loans. The materials
sent to the students should be dated and copies retained in the students’ files as evidence of the University’s
compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized
Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower
ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the
student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b),
(1) & 34 CFR 674.42(b)].
Condition: For 11 of student files examined where students with direct loans withdrew during FY23, we did
not find satisfactory documentation to show that the University complied with exit counseling requirements
for four of them and for six of them, counseling wasn’t done timely (total exceptions 10 out of 11 files where
such counseling was required. Cause: Weak processes and controls over ensuring exit counseling is performed as well as a lack of
recordkeeping to evidence exit counseling requirements were met by the University.
Effect: For students with a break in enrollment, the University did not meet its responsibilities to provide
these individuals with required exit counseling information.
Questioned costs: $-0-.
Perspective information: See table below: Identification of repeat findings: Yes, see FA-2022-003.
Recommendation: The Financial Aid Director should review the Department of Education’s requirements
of Institutions related to exit counseling and implement controls to ensure those requirements are met. We
recommend that the Department of Education’s Direct Loan Exit Counseling Guide be mailed to the
permanent address on record for students who have separated service along with a letter informing them to
read the material and perform exit counseling online as a requirement of their federal loans. The materials
sent to the students should be dated and copies retained in the students’ files as evidence of the University’s
compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution ensure exit counseling is conducted with each Direct Subsidized
Loan or Direct Unsubsidized Loan borrower and graduate borrower shortly before the student borrower
ceases at least half-time study. Exit counseling must be conducted within 30 days after the school learns the
student borrower has withdrawn from school or failed to complete the exit counseling [34 CFR 685.304(b),
(1) & 34 CFR 674.42(b)].
Condition: For 11 of student files examined where students with direct loans withdrew during FY23, we did
not find satisfactory documentation to show that the University complied with exit counseling requirements
for four of them and for six of them, counseling wasn’t done timely (total exceptions 10 out of 11 files where
such counseling was required. Cause: Weak processes and controls over ensuring exit counseling is performed as well as a lack of
recordkeeping to evidence exit counseling requirements were met by the University.
Effect: For students with a break in enrollment, the University did not meet its responsibilities to provide
these individuals with required exit counseling information.
Questioned costs: $-0-.
Perspective information: See table below: Identification of repeat findings: Yes, see FA-2022-003.
Recommendation: The Financial Aid Director should review the Department of Education’s requirements
of Institutions related to exit counseling and implement controls to ensure those requirements are met. We
recommend that the Department of Education’s Direct Loan Exit Counseling Guide be mailed to the
permanent address on record for students who have separated service along with a letter informing them to
read the material and perform exit counseling online as a requirement of their federal loans. The materials
sent to the students should be dated and copies retained in the students’ files as evidence of the University’s
compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student remains eligible to receive financial aid prior to
disbursement of funds. From appendix A of compliance supplement: Student must maintain good standing,
or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11,
20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Satisfactory academic progress (SAP) is defined as
Maintenance of satisfactory progress (2.0 GPA).
Condition: For two of the 49 student files tested receiving financial aid during FY23, the GPA was below
two out of 10 students with unsatisfactory academic progress were allowed to continue to receive federal aid
with no evidence of obtaining a waiver.
Cause: Weak internal control processes over SAP for students as well as the student appeal process.
Effect: For students with a GPA < 2, the University failed to meet its obligation to assist the students with
the appeals process.
Questioned costs: $24,794
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-004.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students with unsatisfactory academic performance students had no documented appeal process for
students to continue to receive aid and develop corrective action as soon as possible to avoid future issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student remains eligible to receive financial aid prior to
disbursement of funds. From appendix A of compliance supplement: Student must maintain good standing,
or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11,
20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Satisfactory academic progress (SAP) is defined as
Maintenance of satisfactory progress (2.0 GPA).
Condition: For two of the 49 student files tested receiving financial aid during FY23, the GPA was below
two out of 10 students with unsatisfactory academic progress were allowed to continue to receive federal aid
with no evidence of obtaining a waiver.
Cause: Weak internal control processes over SAP for students as well as the student appeal process.
Effect: For students with a GPA < 2, the University failed to meet its obligation to assist the students with
the appeals process.
Questioned costs: $24,794
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-004.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students with unsatisfactory academic performance students had no documented appeal process for
students to continue to receive aid and develop corrective action as soon as possible to avoid future issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student remains eligible to receive financial aid prior to
disbursement of funds. From appendix A of compliance supplement: Student must maintain good standing,
or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11,
20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Satisfactory academic progress (SAP) is defined as
Maintenance of satisfactory progress (2.0 GPA).
Condition: For two of the 49 student files tested receiving financial aid during FY23, the GPA was below
two out of 10 students with unsatisfactory academic progress were allowed to continue to receive federal aid
with no evidence of obtaining a waiver.
Cause: Weak internal control processes over SAP for students as well as the student appeal process.
Effect: For students with a GPA < 2, the University failed to meet its obligation to assist the students with
the appeals process.
Questioned costs: $24,794
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-004.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students with unsatisfactory academic performance students had no documented appeal process for
students to continue to receive aid and develop corrective action as soon as possible to avoid future issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student remains eligible to receive financial aid prior to
disbursement of funds. From appendix A of compliance supplement: Student must maintain good standing,
or satisfactory academic progress (34 CFRs 668.16, 668.32(f), 668.34, 690.75, 675.9, 676.9, 685.200, 686.11,
20 USC 1070h; 42 CFR 57.306; 42 USC 293a(d)(2)). Satisfactory academic progress (SAP) is defined as
Maintenance of satisfactory progress (2.0 GPA).
Condition: For two of the 49 student files tested receiving financial aid during FY23, the GPA was below
two out of 10 students with unsatisfactory academic progress were allowed to continue to receive federal aid
with no evidence of obtaining a waiver.
Cause: Weak internal control processes over SAP for students as well as the student appeal process.
Effect: For students with a GPA < 2, the University failed to meet its obligation to assist the students with
the appeals process.
Questioned costs: $24,794
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-004.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students with unsatisfactory academic performance students had no documented appeal process for
students to continue to receive aid and develop corrective action as soon as possible to avoid future issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution refunds calculated for students who withdrew during a semester
be remitted to the Department of Education timely, within 45 days of withdrawal.
Condition: Fourteen students were selected for withdrawal test work. Of those fourteen students, the
Institution calculated an amount that needed to be returned for 8 of those students (four students tested didn’t
have to return any funds, met the requirement to keep all aid received). Six of those eight students who
required funds to be returned based upon their withdrawal terms and resulting return of funding calculations
were not returned timely to the Department of Education.
Cause: Weak process and controls over the return of funds for students who withdrew from the Institution.
Effect: Funds were held in the University’s cash account longer than necessary and such funds were no longer
technically the property of the University after the student withdrew from the University.
Questioned costs: $-0-
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-005.
Recommendation: The University should increase its efforts through training to ensure that federal refunds
are calculated and remitted timely when students withdraw from the Institution.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution refunds calculated for students who withdrew during a semester
be remitted to the Department of Education timely, within 45 days of withdrawal.
Condition: Fourteen students were selected for withdrawal test work. Of those fourteen students, the
Institution calculated an amount that needed to be returned for 8 of those students (four students tested didn’t
have to return any funds, met the requirement to keep all aid received). Six of those eight students who
required funds to be returned based upon their withdrawal terms and resulting return of funding calculations
were not returned timely to the Department of Education.
Cause: Weak process and controls over the return of funds for students who withdrew from the Institution.
Effect: Funds were held in the University’s cash account longer than necessary and such funds were no longer
technically the property of the University after the student withdrew from the University.
Questioned costs: $-0-
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-005.
Recommendation: The University should increase its efforts through training to ensure that federal refunds
are calculated and remitted timely when students withdraw from the Institution.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution refunds calculated for students who withdrew during a semester
be remitted to the Department of Education timely, within 45 days of withdrawal.
Condition: Fourteen students were selected for withdrawal test work. Of those fourteen students, the
Institution calculated an amount that needed to be returned for 8 of those students (four students tested didn’t
have to return any funds, met the requirement to keep all aid received). Six of those eight students who
required funds to be returned based upon their withdrawal terms and resulting return of funding calculations
were not returned timely to the Department of Education.
Cause: Weak process and controls over the return of funds for students who withdrew from the Institution.
Effect: Funds were held in the University’s cash account longer than necessary and such funds were no longer
technically the property of the University after the student withdrew from the University.
Questioned costs: $-0-
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-005.
Recommendation: The University should increase its efforts through training to ensure that federal refunds
are calculated and remitted timely when students withdraw from the Institution.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Regulations require the Institution refunds calculated for students who withdrew during a semester
be remitted to the Department of Education timely, within 45 days of withdrawal.
Condition: Fourteen students were selected for withdrawal test work. Of those fourteen students, the
Institution calculated an amount that needed to be returned for 8 of those students (four students tested didn’t
have to return any funds, met the requirement to keep all aid received). Six of those eight students who
required funds to be returned based upon their withdrawal terms and resulting return of funding calculations
were not returned timely to the Department of Education.
Cause: Weak process and controls over the return of funds for students who withdrew from the Institution.
Effect: Funds were held in the University’s cash account longer than necessary and such funds were no longer
technically the property of the University after the student withdrew from the University.
Questioned costs: $-0-
Perspective information: See table below: Identification of repeat findings: Yes, See FA-2022-005.
Recommendation: The University should increase its efforts through training to ensure that federal refunds
are calculated and remitted timely when students withdraw from the Institution.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student with Verification code V4 or V5 has a high school
completion status and has signed an Identity of education purpose statement.
Condition: For one of the five student files tested that required verification of high school completion and a
signed Identity of education statement of the total 49 students tested who received financial aid during FY23,
the verification process was not documented.
Cause: Weak internal control processes over required verification for students.
Effect: For students with verification codes V4 or V5, the University failed to maintain the student’s signed
Identity of educational purpose statement.
Questioned costs: $7,947
Perspective information: See table below: Identification of repeat findings: Not a repeat finding.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students were not verified properly and develop corrective action as soon as possible to avoid any
further issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student with Verification code V4 or V5 has a high school
completion status and has signed an Identity of education purpose statement.
Condition: For one of the five student files tested that required verification of high school completion and a
signed Identity of education statement of the total 49 students tested who received financial aid during FY23,
the verification process was not documented.
Cause: Weak internal control processes over required verification for students.
Effect: For students with verification codes V4 or V5, the University failed to maintain the student’s signed
Identity of educational purpose statement.
Questioned costs: $7,947
Perspective information: See table below: Identification of repeat findings: Not a repeat finding.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students were not verified properly and develop corrective action as soon as possible to avoid any
further issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student with Verification code V4 or V5 has a high school
completion status and has signed an Identity of education purpose statement.
Condition: For one of the five student files tested that required verification of high school completion and a
signed Identity of education statement of the total 49 students tested who received financial aid during FY23,
the verification process was not documented.
Cause: Weak internal control processes over required verification for students.
Effect: For students with verification codes V4 or V5, the University failed to maintain the student’s signed
Identity of educational purpose statement.
Questioned costs: $7,947
Perspective information: See table below: Identification of repeat findings: Not a repeat finding.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students were not verified properly and develop corrective action as soon as possible to avoid any
further issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The Institution must verify that the student with Verification code V4 or V5 has a high school
completion status and has signed an Identity of education purpose statement.
Condition: For one of the five student files tested that required verification of high school completion and a
signed Identity of education statement of the total 49 students tested who received financial aid during FY23,
the verification process was not documented.
Cause: Weak internal control processes over required verification for students.
Effect: For students with verification codes V4 or V5, the University failed to maintain the student’s signed
Identity of educational purpose statement.
Questioned costs: $7,947
Perspective information: See table below: Identification of repeat findings: Not a repeat finding.
Recommendation: The University should work with the Financial Aid Director to determine the root cause
of why students were not verified properly and develop corrective action as soon as possible to avoid any
further issues.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve
publicly posting completed forms on the Institution’s website. The forms must be conspicuously posted on
the Institution’s primary website on the same page as the reports of the IHE’s activities as to the emergency
financial aid grants to students (Student Aid Portion) are posted. This information must also be updated no
later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition: We tested two quarterly reports prepared by Virginia Union University to verify timely posting
to website and accuracy in reporting. Of the two tested we were not able to verify that one had been posted
timely to VUU’s website and for one of the two tested, the form was not accurate; the amount distributed did
not agree with underlying documentation.
Cause: Weak process and controls over the preparation and review for the compliance over the public
reporting requirements and accurate filing.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: This finding is related to timely posting was identified from testing two of the four
required quarterly reports and timely filing could not be verified for one of the two reports tested and one
report was not accurate.
Identification of repeat findings: Yes, See FA-2022-006.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve
publicly posting completed forms on the Institution’s website. The forms must be conspicuously posted on
the Institution’s primary website on the same page as the reports of the IHE’s activities as to the emergency
financial aid grants to students (Student Aid Portion) are posted. This information must also be updated no
later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition: We tested two quarterly reports prepared by Virginia Union University to verify timely posting
to website and accuracy in reporting. Of the two tested we were not able to verify that one had been posted
timely to VUU’s website and for one of the two tested, the form was not accurate; the amount distributed did
not agree with underlying documentation.
Cause: Weak process and controls over the preparation and review for the compliance over the public
reporting requirements and accurate filing.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: This finding is related to timely posting was identified from testing two of the four
required quarterly reports and timely filing could not be verified for one of the two reports tested and one
report was not accurate.
Identification of repeat findings: Yes, See FA-2022-006.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: The CARES, CRRSAA, and ARP institutional quarterly portion reporting requirements involve
publicly posting completed forms on the Institution’s website. The forms must be conspicuously posted on
the Institution’s primary website on the same page as the reports of the IHE’s activities as to the emergency
financial aid grants to students (Student Aid Portion) are posted. This information must also be updated no
later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Condition: We tested two quarterly reports prepared by Virginia Union University to verify timely posting
to website and accuracy in reporting. Of the two tested we were not able to verify that one had been posted
timely to VUU’s website and for one of the two tested, the form was not accurate; the amount distributed did
not agree with underlying documentation.
Cause: Weak process and controls over the preparation and review for the compliance over the public
reporting requirements and accurate filing.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: This finding is related to timely posting was identified from testing two of the four
required quarterly reports and timely filing could not be verified for one of the two reports tested and one
report was not accurate.
Identification of repeat findings: Yes, See FA-2022-006.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Recipients of HEERF funding must acknowledge that it may not condition the receipt of an
emergency financial aid grant on continued or future enrollment with the Recipient. Recipients also
acknowledge that it may not require a student to consent to the application of the emergency financial aid
grant to the student’s outstanding account balance as a condition of receipt of or eligibility for an emergency
financial aid grant funding. The recipient also acknowledges that adding preconditions to receiving a
financial aid grant that thwart this requirement may be subjected to oversight and corrective action. In
consideration for this award, Recipients agree that they hold these grant funds in trust for students and act in
the nature of a fiduciary for students.
Condition: We tested 36 students receiving student aid to verify that students had been notified of their
award, received the funds directly and funds were applied as student requested on their signed and dated
HEERF Notification and Authorization Form. Of the 36 tested 10 had issues. For 3 students, their account
was credited for the award, and they had authorized payment by check; For 7 students, there was no form
found directing how funds should be disbursed to them from VUU.
Cause: Weak processes and controls over the notification of students of their award and distribution of awards
based on student’s authorization/instruction.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: These findings relate to the inappropriate distribution of awards to student
accounts when students had instructed that their award not be posted to their student’s account and authorized
they be made by check. For the other students the funds were posted to the student accounts and there was no
evidence of authorization from the student.
Identification of repeat findings: Not a repeat finding.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Recipients of HEERF funding must acknowledge that it may not condition the receipt of an
emergency financial aid grant on continued or future enrollment with the Recipient. Recipients also
acknowledge that it may not require a student to consent to the application of the emergency financial aid
grant to the student’s outstanding account balance as a condition of receipt of or eligibility for an emergency
financial aid grant funding. The recipient also acknowledges that adding preconditions to receiving a
financial aid grant that thwart this requirement may be subjected to oversight and corrective action. In
consideration for this award, Recipients agree that they hold these grant funds in trust for students and act in
the nature of a fiduciary for students.
Condition: We tested 36 students receiving student aid to verify that students had been notified of their
award, received the funds directly and funds were applied as student requested on their signed and dated
HEERF Notification and Authorization Form. Of the 36 tested 10 had issues. For 3 students, their account
was credited for the award, and they had authorized payment by check; For 7 students, there was no form
found directing how funds should be disbursed to them from VUU.
Cause: Weak processes and controls over the notification of students of their award and distribution of awards
based on student’s authorization/instruction.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: These findings relate to the inappropriate distribution of awards to student
accounts when students had instructed that their award not be posted to their student’s account and authorized
they be made by check. For the other students the funds were posted to the student accounts and there was no
evidence of authorization from the student.
Identification of repeat findings: Not a repeat finding.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.
Criteria: Recipients of HEERF funding must acknowledge that it may not condition the receipt of an
emergency financial aid grant on continued or future enrollment with the Recipient. Recipients also
acknowledge that it may not require a student to consent to the application of the emergency financial aid
grant to the student’s outstanding account balance as a condition of receipt of or eligibility for an emergency
financial aid grant funding. The recipient also acknowledges that adding preconditions to receiving a
financial aid grant that thwart this requirement may be subjected to oversight and corrective action. In
consideration for this award, Recipients agree that they hold these grant funds in trust for students and act in
the nature of a fiduciary for students.
Condition: We tested 36 students receiving student aid to verify that students had been notified of their
award, received the funds directly and funds were applied as student requested on their signed and dated
HEERF Notification and Authorization Form. Of the 36 tested 10 had issues. For 3 students, their account
was credited for the award, and they had authorized payment by check; For 7 students, there was no form
found directing how funds should be disbursed to them from VUU.
Cause: Weak processes and controls over the notification of students of their award and distribution of awards
based on student’s authorization/instruction.
Effect: Potential issues with the Department of Education regarding noncompliance.
Questioned costs: $-0-
Perspective information: These findings relate to the inappropriate distribution of awards to student
accounts when students had instructed that their award not be posted to their student’s account and authorized
they be made by check. For the other students the funds were posted to the student accounts and there was no
evidence of authorization from the student.
Identification of repeat findings: Not a repeat finding.
Recommendation: The University should increase its efforts to ensure that major program compliance
requirements are understood, and controls are implemented to ensure compliance.
Views of responsible officials: See Client’s Corrective Action Plan.